Greetings!

Today we're hosting our Friday afternoon member call on COVID-19 at 3:30 pm. You need to register in advance for the call, but if have done so previously, you should already have the call-in info.
 
This message also includes:
  • information on the CMS interim rule on nursing home COVID-19 reporting requirements; and
  • links to the information we have previously provided related to the Medicaid $20 per day add on for nursing facilities.

We look forward to talking with everyone at 3:30 pm.

Sincerely,

April Payne, LNHA
Vice President of Quality Improvement | Director of VCAL
Virginia Health Care Association | Virginia Center for Assisted Living 
VHCA-VCAL Member Call: COVID-19
May 1, 2020 | 3:30 pm
 
Register for the meeting:

After registering, you will receive a confirmation email containing information about joining the meeting, including calendar notices for the calls over the next month.

Agenda
  1. Welcome | Novel Martin | Chairman of the Board
  2. Update from VHCA-VCAL | Keith Hare | President and CEO
  3. Medicaid and Funding Update | Steve Ford | Senior Vice President of Policy and Reimbursement
  4. VDH Update | Sarah Lineberger | Healthcare-Associated Infections Program Manager
  5. Hot Topic Review | April Payne | Vice President of Quality Improvement and Director of VCAL

Please mute your line to improve the sound quality on the call. Zoom has a chat feature you can use to send questions or comments.
CMS Issues Interim Final Rule with New Requirements for COVID-19 Reporting for Nursing Homes

Last night, CMS issued an interim final rule with comment period which revises § 483.80 establishing explicit reporting requirements for long term care (LTC) facilities to report information related to COVID-19 cases among facility residents and staff. These reporting requirements are applicable on the effective date of this interim final rule which is the date of the publication at the Office of the Federal Register. AHCA will notify members when it is published.

Under this new requirement nursing facilities must: 
 
Electronically Report to CDC’s National Healthcare Safety Network (NHSN)
  • Electronically report information about COVID-19 in a standardized format specified by the Secretary of Health and Human Services (HHS), which will rely on CDC NHSN portal that went live on April 29 with the new LTCF COVID-19 module. This report to CDC must include but is not limited to:
  • Suspected and confirmed COVID-19 infections among residents and staff, including residents previously treated for COVID-19; 
  • Total deaths and COVID-19 deaths among residents and staff; 
  • Personal protective equipment and hand hygiene supplies in the facility; 
  • Ventilator capacity and supplies in the facility; 
  • Resident beds and census; 
  • Access to COVID-19 testing while the resident is in the facility; 
  • Staffing shortages; and 
  • Other information specified by the Secretary. 
  • Provide the information specified in the list above at a frequency specified by the HHS Secretary, but no less than weekly to NHSN.
  • This information will be posted publicly by CMS to support protecting the health and safety of residents, personnel, and the general public. 

In addition, providers must continue to comply with state and local reporting requirements for COVID-19. AHCA will continue to advocate to align state and CDC reporting to avoid duplication of effort that is taking staff away from resident care. 
 
Inform Residents, their Representatives, and Families 
  • Inform residents, their representatives, and families of those residing in facilities by 5:00 pm the next calendar day following the occurrence of:
  • Either a single confirmed infection of COVID-19, or 
  • Three or more residents or staff with new-onset of respiratory symptoms occurring within 72 hours of each other. 
  • This information must:
  • Not include personally identifiable information; 
  • Include information on mitigating actions implemented to prevent or reduce the risk of transmission, including if normal operations of the facility will be altered; and 
  • Include any cumulative updates for residents, their representatives, and families at least weekly or by 5:00 pm the next calendar day following the subsequent occurrence of either: 
  • Each time a confirmed infection of COVID-19 is identified, or 
  • Whenever three or more residents or staff with new onset of respiratory symptoms occur within 72 hours of each other.
  • The preamble to the rule states that facilities are not expected to make individual calls. Providers may use general communication platforms easily available to residents, representatives and families such as listservs, website postings, and recorded telephone messages.

AHCA will continue to advocate for CMS to issue clarifying language that makes this feasible and as least burdensome as possible. 
Important Reminders about the
Medicaid $20 Per Day Add-On

As we have shared previously, DMAS finalized the  guidance and templates and the roster billing process for the per diem add-on is live.  Banking information was requested from nursing facilities for EFT set-up at the managed care organizations (MCOs) by April 29 and rosters for the March 12-31 period were requested by today, May 1. Submitters that meet those deadlines should receive payments by May 15. If you do not meet one or both of those deadlines, submit the information as soon as you can, but understand that payment may not be made by May 15.

Subsequent to the finalization of the guidance, several questions have come up requiring clarification:
  1. Use the DMAS-approved spreadsheet template do not modify it or convert it to a different format (like a PDF) (NB: The Fee-for-Service spreadsheet includes hospice tabs; the MCO spreadsheet should be used to create individual MCO submissions.)
  2. Use a separate spreadsheet for each payer (FFS and a unique one for each of the MCOs); copy the FFS address on each of the MCO submissions.
  3. Do not password protect the spreadsheet, but send the email encrypted due to PHI. If you do not have your own encryption solution, email each payer and ask them to send you an encrypted email to which you can reply with your submission (within their encryption service). This may require you to set up a password but will allow you to use their system going forward.
  4. Double check the Medicaid ID numbers for accuracy.
  5. The number of days should follow billing rules–do not include the discharge date.
  6. Hospice: In addition to the previous guidance, the NPI on the FFS hospice tabs is for the hospice NPI.
  7. Specialized Care: If you also provide specialized care (a distinct Medicaid service – only a handful do this), we have asked whether or not those should be reported on a separate tab or within the NF days. We have no gotten an answer as of this article. We are suggesting you do one of two things:
  • Just report them on the same tab as NF days and understand that you may need to re-submit or provid additional distinguising information after the fact. 
  • Hold the specialized care days from the March span and include them on your April dates submission due by May 8 as hopefully DMAS will provid the answer by then.

PACE: If you have residents who are enrolled in PACE, we do not yet know if they are included for the add-on (we have asked). We are suggesting that you should not include them on your FFS submission (nor the MCOs) until DMAS answers the question. We do suggest you examine you contract with the PACE organization(s) to determine if your contract ties your reimbursement to the prevailing Medicaid rate; if so, the PACE organization may already be obligated to pay you the additional $20 per day. We continue to wait for DMAS guidance on PACE

If you have additional questions, please email  Steve Ford.
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